The California Tax Credit Allocation Committee (CTCAC) recently released proposed regulation changes to the 2012 Tax Credit program and subsequently conducted a 30 day public comment period in which four public hearings were held to receive feedback on the proposed changes. The National Council of Affordable Housing Market Analysts (NCAHMA), along with 42 other individuals and organizations, formally commented on CTCAC’s proposals.
In response to the feedback the agency received, CTCAC has released a finalized list of recommendations to be considered by the Committee. Below are a few of the major additions to CTCAC’s market study guidelines as a direct result of the comments NCAHMA provided.
CTCAC now proposes that market studies will be updated when either proposed subject rents change by more than five percent, or the distribution of higher rents increases by more than five percent, or 180 days have passed since the first site inspection date of the subject property and comparable properties. CTCAC noted that agency staff “agrees with the comment that small changes in proposed rents ought not to trigger a new market study.”
The agency has also proposed a clarification to the rural policy such that the policy only applies if a second new construction project is underway in the market area. CTCAC notes that “under this [updated] policy, new awards could be considered and made while the first project is initially renting up. This is reasonable since the second project would not be completed for approximately two years following the first project’s completion. So, the two projects would not be simultaneously competing for the same initial tenants.”
To view the complete finalized list of proposed changes to CTCAC’s 2012 Housing Tax Credit Program, click here.
To view a clean and strikeout version of the state’s market study guidelines, click here.
